Could a Blind Person Use Your Website?

May 10, 2017 at 11:08 am Leave a comment

One of the tricky things about dispensing compliance/legal advice to institutions as diverse in size as credit unions is the need to balance providing a heads up about emerging issues against helping credit unions prioritize truly pressing concerns.

With this sanctimonious lead, one of your faithful blogger’s take aways from this year’s Mortgage Bankers Association Legal and Compliance Conference is that it is time for your credit union to begin viewing its website as an extension of your physical infrastructure that is subject to the American’s with Disabilities Act (ADA).  I have been hesitant to talk about this issue for several months because the exact legal framework that your credit union is operating under remains unsettled.  For example, key regulations promised over and over again by the Department of Justice have never been finalized. It is still an open question when a public website is subject to public accommodations for the disabled.

Conversely, there are plenty of anecdotes that website lawsuits are on the rise. In one break out session, most of the audience indicated they had received letters threating legal action over their websites.

Ok Henry, how exactly do I make my website accessible? The standard is something called the Web Content Accessibility Guidelines 2.0 (WCAG 2.0 ). The basic idea is to ensure that your website can accommodate persons with sensory and physical disabilities that make it difficult for them to use a mouse, for example, or read text. If you haven’t already discussed this framework with your IT department and/or vendor, you should. The reality is that as more and more of your services are predicated on your members interacting with your website, it not only makes good compliance sense but simply good business sense to make sure that your member can interface with the products and services that you offer.

Ultimately, no two credit unions could or should address this issue the same way, but we have reached a point where they should be addressed in an ongoing and systematic way. Remember, your physical branch activities are already subject to the ADA reasonable accommodation standards such as 28 CFR 32.303(a), with the caveat that you never have to take steps that would cause an undue burden on your institution. In other words, this is an area where size and resources are going to shape your legal requirements.

Entry filed under: General.

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Authored By:

Henry Meier, Esq., General Counsel, New York Credit Union Association.

The views Henry expresses are Henry’s alone and do not necessarily reflect the views of the Association.

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